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§ 10.1 VALUATION OF PROPERTYappealed from here has no discernable logic. We are not prepared to permitthe . . . [court below], whenever it disagrees with the valuations offered byboth sides, simply to shut its eyes and pick at random any number that happensto lie somewhere between the Commissioner’s valuation and the taxpayer’s.Only by happenstance will such a blind choice avoid a valuation thatis either unacceptably low or unacceptably high. The random walk approach,which leaves no trail for the appellate court to follow, may be a sensible wayto pick stocks, but it is not an appropriate way to determine the value of acharitable donation. 33• A donor contributed 30 gravesites to a church. The donor claimed adeduction of $15,000. The IRS contested that valuation. The court concludedthat the sites had a value of $4,000. 34• A court determined the fair market value of a donated scenic easement byusing the basis of the property as a single parcel, rather than on the basisof its potential for subdivision into 24 lots. 35 The court wrote that, inascertaining the value of land, the “appropriate question is what a hypotheticalMalcolm Forbes would have paid for it as one tract, rather thanwhat two dozen hypothetical yuppies would have paid for it” as 24 lots. 36• Two donors contributed gravesites to charitable organizations. Theyclaimed a charitable deduction of $300 per site. The IRS contested thatvaluation. The court found the value to be $60 per site. 37• A charitable deduction was allowed for the installation and transfer ofdrainage facilities and easements to a city. The IRS denied the deduction.The court found the value to be about twice that asserted by the IRS. 38• A court held that there was no deduction for a contribution, by the spouseof a deceased psychoanalyst, of the decedent’s correspondence andmanuscripts because the material lacked any value. 39• A donor contributed bandages to an international relief organization. Thedonor claimed a value of $45,600. The IRS contested the valuation. Thecourt found the property to have a value of $4,211. 40• A number of individuals contributed an easement to a natural wildlifehabitat. The value of the easement was litigated. The IRS asserted apregift value of $475,000 and a postgift value of $47,500. The court foundthat the property was valued at $1,165,000 prior to contribution of theeasement and $100,000 after the contribution. 4133 Stark v. Commissioner, 1986 T.C.M. (P-H) 61,000 (5th Cir. 1986).34 Sandler v. Commissioner, 52 T.C.M. (CCH) 563 (1986).35 Akers v. Commissioner, 799 F.2d 243 (6th Cir. 1986), aff’g 48 T.C.M. (CCH) 1113 (1984).36 Id., 799 F.2d at 245. The appellate court termed the difference between the two valuations as being “ratherlike the difference between the worth of a gravid or potentially gravid sow and the postpartum worth of sowcum-shoats.”Id.37 Broad v. Commissioner, 52 T.C.M. (CCH) 12 (1986).38 Osborne v. Commissioner, 87 T.C. 575 (1986).39 Strasser v. Commissioner, 52 T.C.M. (CCH) 1130 (1986).40 Tallal v. Commissioner, 52 T.C.M. (CCH) 1017 (1986).41 Stotler v. Commissioner, 53 T.C.M. (CCH) 973 (1987). 359